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TransparencyReport 2018

EY Greece

Transparency Report 2018: EY Greece 2

ContentsMessage from the Country Managing Partner and the EY Greece Assurance Leader ........................................................... 3

About us ...................................................................................................................................................................... 5

Legal structure, ownership and governance ................................................................................................................. 5

Network arrangements .............................................................................................................................................. 8

Commitment to quality ................................................................................................................................................ 10

Infrastructure supporting quality............................................................................................................................... 10

Instilled professional values ...................................................................................................................................... 11

Internal quality control system .................................................................................................................................. 12

Client acceptance and continuance ............................................................................................................................ 13

Performance of audits ............................................................................................................................................. 14

Review and consultation .......................................................................................................................................... 15

Audit partner rotation .............................................................................................................................................. 16

Audit quality reviews ............................................................................................................................................... 16

External quality assurance review ............................................................................................................................. 17

Compliance with legal requirements .......................................................................................................................... 17

Independence practices ............................................................................................................................................... 18

Continuing education of audit professionals .................................................................................................................. 20

Revenue and remuneration .......................................................................................................................................... 21

Financial information ............................................................................................................................................... 21

Partner remuneration .............................................................................................................................................. 21

Appendix 1 ................................................................................................................................................................. 23

Appendix 2 ................................................................................................................................................................. 24

More information about EY can be found at ey.com.


Message from the Country Managing Partner and theEY Greece Assurance Leader

Welcome to the 2018 Transparency Report of Ernst & Young (Hellas) Certified Auditors Accountants S.A. (”EY Hellas”). We believethat how we advance audit quality, manage risk and maintain our independence as auditors should be transparent to ourstakeholders. We value regular dialogue, and this report is one of the ways in which we advise our stakeholders on what we aredoing in each of these areas.

Executing high-quality audits continues to be our top priority and is at the heart of our commitment to serve the public interest. Itenables us to grow the global EY network successfully and responsibly, while achieving our purpose of building a better workingworld. Auditors play a vital role in the functioning of capital markets by promoting transparency and supporting investor confidence.Companies, regulators and other stakeholders count on us to deliver excellence in every engagement.

We are focused on investing in tools to improve what we do, creating the highest-performing teams, and building trust andconfidence in the audits we perform.

EY Hellas’ reputation is based on and grounded in providing high-quality professional audit services objectively and ethically toevery company we audit.

We continue to embrace the transparency objectives of the European Union’s 8th Company Law Directive, EU Regulation 537/2014and Law 4449/2017, which require Greek statutory auditors of public interest entities (PIEs) to publish annual transparencyreports.

The 2018 EY Hellas Transparency Report complies with the Directive, EU Regulation 537/2014 and Law 4449/2017, and coversthe fiscal year ending 30 June 2018. In this report, you can learn more about our internal quality control system: how we instillprofessional values, how we perform an audit, our review and consultation processes, our approach to audit quality reviews, andour independence practices.

EY Hellas is focused on enhancing audit quality and upholding our independence, informed by several matters including externaland internal inspection results. Continuous improvement of audit quality requires us to challenge approaches to audit execution,and we focus on this by evaluating all inspection findings and taking responsive actions.

As a result of our internal procedures on internal control system of EY Hellas, we consider this as effective. Furthermore, all policiesrelating to independence described in this Transparency Report have been followed and internal review procedures have beenperformed with respect to the independence compliance for all statutory audit engagements.


At EY we apply all components and initiatives of the Global Sustainable Audit Quality program, with continuous emphasis on initiatives implemented in prior year around audit milestones, archiving, Root Cause Analysis, continuous education monitoring compliance etc.

We are closely following up on the developments in our profession, including the launch of new technologies in the audit process, and the increase of standardization, simplification and accountability. During this year, we created an internal audit shared service centre (central audit unit – hub) which aims to support all audit teams in a large number of audit tasks, thus increase the rate of standardization. Except for standardization and centralization, this operational unit also focuses to the introduction of innovation in the audit process through the use of existing and new technologies and the massive penetration of Data Analytics techniques in the core audit process. Our aim is to achieve a direct positive impact on quality through this initiative.

We are exploring new methods of training with the aim to increase the effectiveness and the flexibility of the learning process. We make available all different methods and types of training to our professionals through different training channels. We are working very closely with all associations and institutes and with our training partners and actively support them in their initiatives.

We aim to maintain open dialogue with all stakeholders of the audit profession in the country, including regulators, professional associations, universities, our employees and our clients.

We encourage all our stakeholders — including our clients and their investors, audit committee members and regulators — to continue to engage with us on our strategy as well as any of the matters covered in this report.

For Ernst & Young (Hellas) Certified Auditors Accountants S.A.

Panagiotis I. K. Papazoglou Vassilios KaminarisCountry Managing Partner Country Assurance Leader

EY’s purpose: building a better working worldEY is committed to doing its part in building a better working world.

The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to stakeholders. In so doing, we play a critical role in building a better working world for our people, our clients and our communities.


About usLegal structure, ownership andgovernanceIn Greece, Ernst & Young (Hellas) Certified AuditorsAccountants S.A. is a Societe Anonyme organized in Athens,Greece and is a member firm of Ernst & Young GlobalLimited, a UK company limited by guarantee (EYG). EYrefers collectively to the global organization of the memberfirms of EYG.

EY Hellas was incorporated as a Greek Societe Anonyme on7 December 1990. Its registered seat is located in MarousiAttica (Address: Chimarras Street n. 8B).

EY Hellas is registered in the registries of the Prefecture ofAttica, General Directorate of Development, Region of NorthAthens, Directorate of Development, Department forSocietes Anonymes, with the registration number:23013/01/Β/90/ 394/ (2002).

Furthermore, EY Hellas is registered in the General Registryof Companies (GEMI) with the registration number000710901000.

The company is registered with the Body of CertifiedAuditors Accountants of Greece with registration number107.

Ownership Structure

The shares of EY Hellas are registered, undivided andrestricted according to art. 6 of its Articles of Association.The restriction consists of the provision by the shareholders’meeting of the company of its approval prior to any transfer.

The shareholders of EY Hellas are the following:

1. The legal entity under the trade name “ERNST & YOUNGSOUTHEAST EUROPE PUBLIC LIMITED”, a companyestablished under the laws of Cyprus, with its registeredseat at 6 Stasinos Avenue, Jean Nouvel Tower, 1060Nicosia.

Shareholders of “ERNST & YOUNG SOUTHEAST EUROPEPUBLIC LIMITED”, are the following individuals and legalentity:

a) the legal entity under the trade name “ERNST &YOUNG EUROPE LLP”, a limited liability partnershipestablished under the laws of England and Wales andits registered seat is at Becket House, 1 Lambethpalace Road, London SE1 7EU,

b) individuals who hold preference non - voting shares.

2. The legal entity under the trade name “ERNST & YOUNGCYPRUS LIMITED”, a company established under thelaws of Cyprus with its registered seat at 6 StasinosAvenue, Jean Nouvel Tower, 1060 Nicosia. Its soleshareholder is “ERNST & YOUNG” a partnershipestablished under the laws of Cyprus, having itsregistered offices at 6 Stasinos Avenue, Jean NouvelTower, 1060 Nicosia, the Partners of which are thefollowing:

a) Stavros Pantzaris, son of Christos.

b) Philippos Raptopoulos, son of Zacharias.

c) Yiannakis Theoklitou, son of Socratis.

d) Savvas Pentaris, son of Fotios.

e) Stelios Demetriou, son of Andreas.

f) Andreas Avraamides, son of Stavros.

g) Petros Liassides, son of Liasis.

h) Nikolaos Nicolaou, son of Charalampos and

i) ERNST & YOUNG SOUTHEAST EUROPE BUSINESSADVISORY SERVICES LIMITED, a companyestablished and operating under the laws ofCyprus, having its registered seat at 6 StasinosAvenue, Jean Nouvel Tower, 1060 Nicosia, the solepartner of which is the company ERNST & YOUNGSOUTHEAST EUROPE PUBLIC LIMITED.

Reference to “ERNST & YOUNG SOUTHEAST EUROPEPUBLIC LIMITED” and its shareholders is made above.

EY Greece also includes the other EYG member firm, whichhas been incorporated according to the provisions of Greeklaw and operates in Greece:

� ERNST & YOUNG Societe Anonyme for the Provision ofAdvisory Services with the distinctive title “Ernst &Young Business Advisory Solutions”.


It is noted that “ERNST & YOUNG REGIONAL ACCOUNTINGSERVICES SOLE PARTNER LIMITED LIABILITY COMPANYUNDER LIQUIDATION” was de-registered on 4 April 2018and the liquidation is completed.

Whenever reference is made to the present TransparencyReport to “EY Greece”, “we,” “us” or “our”, it shall bedeemed to refer collectively to the aforementionedmember-firms of EYG in Greece.

EY Hellas has established a branch in Thessaloniki, Greece.The branch’s address is Polytechniou 4 & N. Limnou-ChapsaStreet.

Another EYG member in Greece is the law firm “Platis -Anastassiadis & Associates LAW PARTNERSHIP” with thedistinctive title “PLATIS-ANASTASSIADIS & ASSOCIATES”.

Governance – Board of Directors

Various partners at EY Hellas are charged with managementfunctions for EY Hellas. These partners are responsible forall day to day management activity and for the applicationof global and area level policy at the country level. Details ofthe formal/legal governing bodies of EY Hellas are givenbelow.

The Members of the Board of Directors of EY Hellas as ofAugust 3, 2017 are the following:

1. Panagiotis Papazoglou, son of Ioannis-Konstantinos,Chairman and Managing Director.

2. Vassilios Kaminaris, son of George, Vice-Chairman.

3. Dimitrios Konstantinou, son of Christoforos, Member.

4. Christos Pelendridis, son of Anastassios, Member.

5. Ioannis Pierros, son of Antonios, Member.

6. Stefanos Mitsios, son of Ilias, Member.

7. Sofia Kalomenidou, daughter of George, Member.

8. Christianna Panagidou, daughter of Kostakis, Member.

9. Andreas Chatzidamianou, son of George, Member.

10. Kostas Stathopoulos son of Konstantinos, Member.

11. Evangelos Analitis son of Stavros, Member.

The general management and representation of EY Hellasbefore public and private authorities in Greece and abroadis exercised either by the Chairman of the Board andManaging Director, Mr. Panagiotis Papazoglou, who bindsthe company by his sole signature, or by the company’s Vice– Chairman Mr. Vassilios Kaminaris who also binds thecompany by his sole signature or by the Member of thecompany’s Board of Directors, Mr. Dimitrios Constantinou,who also binds the company by his sole signature.

As regards the realization of bank transactions, i.e.indicatively the issuance, endorsement of Checks, of bills ofexchange or of other promissory notes, the withdrawal ofmoney etc. (hereafter the “Banking Transactions”), thefollowing apply:

1. For Banking Transactions of an amount up to 10,000Euro, the joint signature of two of the followingpersons is required: a) either the joint signature of Mr.Nikolaos Nikolakis, son of Ioannis, and Mr. SpyridonKatsikis, son of Athanasios, or b) the joint signature ofany two members of the Board of Directors.

2. For Banking Transactions of exceeding the amount of10,000 Euro, the joint signature of the followingpersons is required: a) either the joint signature of anytwo of the members of the Board of Directors, or b) thejoint signature of Mr. Nikolakis and any member of theBoard of Directors, or c) the joint signature of Mr.Katsikis and any member of the Board of Directors.

3. For the signature of accounting - administrative andfinancial reports, experts’ reports, reports of theSpecial Tax Audit (Tax Certificate), of agreements ofthe Company with its clients and other companies-members of the network of Ernst & Young of anyamount, of confidentiality agreements with clientsand/or prospective clients, of consortium/teamingagreements and/or sub-contract agreements withthird parties, as well as solemn declarations anddocuments addressed to Tax Authorities in Greecerelating to the payment of invoices of suppliers of theCompany, proposals to clients irrespective of theamount, engagement letters irrespective of theamount and Company’s invoices irrespective of theamount, suffices the sole signature of either theChairman of the Board of Directors and ManagingDirector, Mr. Panagiotis Papazoglou or the solesignature of Vice chairman Mr. Vassilios Kaminaris orthe sole signature of any of the members of the Boardof the Directors or the sole signature of one of thebelow mentioned individuals:

1. Georgios Anastopoulos, son of Anastasios.

2. Konstantinos Tsekas, son of Socrates.

3. Konstantinos Katsagannis, son of Vassilios.

4. Maria Chatziantoniou, daughter of Theodoros.

5. Vassilios Kaplanis, son of Panagiotis.

Additionally, Mr. Ioannis Dracoulis, son of Vassilios, isauthorized to sign factual findings reports, contracts withclients and other EY Member firms, without limitation to theamount, confidentiality agreements with clients and/orprospective clients, of consortium/teaming agreementsand/ or sub-contract agreements with third parties, as wellas solemn declarations and documents addressed to TaxAuthorities in Greece relating to the payment of invoices ofsuppliers, offers of the Company without limitation to theamount as well as engagement letters and invoices of theCompany without limitation to the amount.

Furthermore, Mr. Konstantinos Katsagannis is authorised torealize transactions with his sole signature of the bankaccount with the number 0026-0016-16-0200-167-183,which the Company keeps in EFG Eurobank Bank, which isused by the branch of the Company in Thessaloniki, to


withdraw money, to issue and endorse checks and to issue,accept and endorse exchanges and bills of exchange, torealise payments on behalf of the Company, provided thatthe above transactions do not overcome the amount of5,000 Euro, and to sign in the name and on behalf of theCompany agreements regarding the operational needs ofthe branch of the Company at Thessaloniki, provided thatthe scope of such agreements does not exceed in value theamount of 5,000 Euro.

For the execution of labor and freelance agreements of theCompany, the sole signature of any member of the Board ofDirectors or the sole signature of any of the followingpersons is sufficient: Mrs. Ioli Katsiroumpa daughter ofIoannis, or Mrs. Asteria Kalamara daughter of Zacharias orMrs. Alexandra Vraka daughter of Nikolaos.

Additionally, Mrs. Ioli Katsiroumpa, Mrs. Asteria Kalamaraand Mrs. Alexandra Vraka are authorised (each actingseparately) to execute in the name and on behalf of theCompany documents addressed to the Commission of Work(indicatively personnel lists, any kind of notifications,applications for the approval of overtime work and otherapplications etc.), to the Social Security Fund (IKA)(indicatively any kind of notifications, sickness papers ofemployees, employer’s certificates relating to stamps etc.)to OAED (indicatively any kind of documents andnotifications etc.) as well as employment certificates for theemployees of the Company, offer letters addressed to futureemployees of the Company and any letter addressed toinsurance companies, hospitals and medical centers inGreece and abroad.

Finally, copies of minutes of Board of Directors meetings andShareholders’ Meetings may be issued by either theChairman of the Board of Directors and Managing Director,Mr. Panagiotis Papazoglou or the Vice-Chairman of theBoard of Directors, Mr. Vassilios Kaminaris or the Member ofthe Board of Directors, Mr. Dimitrios Konstantinou.

EYG member firms are grouped into four geographic Areas:Americas; Asia-Pacific; Europe, Middle East, India and Africa(EMEIA); and Japan. The Areas comprise a number ofRegions, which consist of member firms or sections of thosefirms.

EY Hellas is part of the EMEIA Area, which comprises EYGmember firms in 98 countries in Europe, the Middle East,India and Africa. Within the EMEIA Area, there were 11Regions, and from 1 July 2018 the number has reduced to10. EY Hellas is part of the CESA Region.

Ernst & Young (EMEIA) Limited (“EMEIA Limited”), anEnglish company limited by guarantee, is the principalcoordinating entity for the EYG member firms in the EMEIAArea. EMEIA Limited facilitates the coordination of thesefirms and cooperation between them, but it does not controlthem. EMEIA Limited is a member firm of EYG, has nofinancial operations and does not provide any professionalservices.

Each Region elects a Regional Partner Forum (RPF), whoserepresentatives advise and act as a sounding board toRegional leadership. The partner elected as PresidingPartner of the RPF also serves as the Region’srepresentative on the Global Governance Council(see page 8).

In Europe, a holding entity, Ernst & Young Europe LLP (“EYEurope”), was formed in conjunction with EMEIA Limited. EYEurope is an English limited liability partnership, owned bypartners of the EYG member firms operating in Europe. It isan audit firm registered with the Institute of CharteredAccountants in England and Wales (ICAEW), but it does notcarry out audits or provide any professional services. To theextent permitted by local legal and regulatory requirements,EY Europe has acquired or will acquire voting control of theEYG member firms operating in Europe. EY Europe is amember firm of both EYG and EMEIA Limited.

EY Europe acquired voting control of EY Hellas as of 2February 2011.

EY Europe’s principal governing bodies are:

Europe Operating ExecutiveThe Europe Operating Executive (EOE) operates as theboard of EY Europe. It has authority and accountability forstrategy execution and management of EY Europe’soperations. The EOE comprises: the Europe ManagingPartner; the leaders for Accounts, Talent and RiskManagement; the service line leaders for Assurance,Advisory, Transaction Advisory Services and Tax; and allEuropean Regional Managing Partners.

Europe Governance Sub-CommitteeEY Europe has the Europe Governance Sub-Committee,which includes one representative from each Region inEurope. It serves in an advisory role to the EOE on policies,strategies and other matters, and its approval is required fora number of significant matters, such as the appointment ofthe Europe Managing Partner, approval of the financialreports of EY Europe and material transactions.

Subsequent EventsBy virtue of the Board of Directors Meeting Minutes of EYHellas dated 2 July 2018, Mr. Vassilios Tzifas, son ofNikolaos, was authorized to sign accounting - administrativeand financial reports, experts’ reports, reports of theSpecial Tax Audit (Tax Certificate), of agreements of theCompany with its clients and other companies-members ofthe network of Ernst & Young of any amount, ofconfidentiality agreements with clients and/or prospectiveclients, of consortium/teaming agreements and/or sub-contract agreements with third parties, as well as solemndeclarations and documents addressed to Tax Authorities inGreece relating to the payment of invoices of suppliers ofthe Company, proposals to clients irrespective of theamount, engagement letters irrespective of the amount andCompany’s invoices irrespective of the amount.


Network arrangementsEY is a global leader in assurance, tax, transaction andadvisory services. Worldwide, over 250,000 people inmember firms in more than 150 countries share acommitment to building a better working world, united byshared values and an unwavering commitment to quality,integrity and professional skepticism. In today’s globalmarket, the integrated EY approach is particularlyimportant in the delivery of high-quality multinationalaudits, which can span nearly every country in the world.

This integrated approach enables EY member firms todevelop and draw upon the range and depth of experiencerequired to perform such diverse and complex audits.

EYG coordinates the member firms and promotescooperation among them. EYG does not provide services,but its objectives include the promotion of exceptional high-quality client service by member firms worldwide.

Each member firm is a legally distinct entity. Theirobligations and responsibilities as members of EYG aregoverned by the regulations of EYG and various otheragreements.

The structure and principal bodies of the global organizationduring the year ended 30 June 2018 are described below.They reflect the principle that EY, as a global organization,has a common shared strategy.

The Executive includes the Global Executive (GE), itscommittees and teams, and the leadership of the four Areas.At the same time, the network operates on a Regional levelwithin the Areas. This operating model allows for greaterstakeholder focus in the 27 Regions, permitting memberfirms to build stronger relationships with clients and othersin each country, and be more responsive to local needs.

Global Governance CouncilThe Global Governance Council (GGC) is the main oversightbody of EYG. It comprises one or more representatives fromeach Region, other member firm partners as at-largerepresentatives and up to six independent non-executives(INEs). The Regional representatives, who otherwise do nothold senior management roles, are elected by their RPFs fora three-year term, with provision for one successivereappointment. The GGC advises EYG on policies, strategiesand the public interest aspects of its decision—making. Theapproval of the GGC is required for a number of significantmatters that could affect EY.

Independent Non-ExecutivesUp to six Independent Non-Executives (INEs) are appointedfrom outside EY. The INEs are senior leaders from both thepublic and private sectors, and reflect diverse geographicand professional backgrounds. They bring to the globalorganization, and the GGC, the significant benefit of theirvaried perspectives and depth of knowledge. The INEs alsoform a majority of the Public Interest Sub-Committee of theGGC, which addresses public interest matters, includingpublic interest aspects of decision-making, issues raised

under whistleblowing policies and procedures, perspectiveson stakeholder views and engagement in quality and riskmanagement discussions. The INEs are nominated by adedicated committee.

Global ExecutiveThe Global Executive (GE) brings together EY’s leadershipfunctions, services and geographies. It is chaired by theChairman and CEO of EYG, and includes its Global ManagingPartners of Client Service and Business Enablement; theArea Managing Partners; the global functional leadershipfor Talent and Finance; the leaders of the global service lines— Assurance, Advisory, Tax and Transaction AdvisoryServices; the Global Leader for Public Policy; and one EYGmember firm partner on rotation.

The GE also includes the Chair of the Global AccountsCommittee and the Chair of the Emerging MarketsCommittee, as well as a representative from the EmergingMarkets practices.

The GE and the GGC approve nominations for the Chairmanand CEO of EYG, and ratify appointments of the GlobalManaging Partners. The GE also approves appointments ofGlobal Vice Chairs. The GGC ratifies the appointments of anyGlobal Vice Chair who serves as a member of the GE.

The GE’s responsibilities include the promotion of globalobjectives and the development, approval, and, whererelevant, implementation of:

• Global strategies and plans• Common standards, methodologies and policies to be

promoted within member firms• People initiatives, including criteria and processes for

admission, evaluation, development, reward andretirement of partners

• Quality improvement and protection programs• Proposals regarding regulatory matters and• public policy• Policies and guidance relating to member firms’ service

of international clients, business development, marketsand branding

• EY’s development funds and investment priorities• EYG’s annual financial reports and budgets• GGC recommendations

The GE also has the power to mediate and adjudicatedisputes between member firms.

GE committees

Established by the GE and bringing together representativesfrom the four Areas, the GE committees are responsible formaking recommendations to the GE. In addition to theGlobal Audit Committee, there are committees for GlobalMarkets and Investments, Global Accounts, Emerging


Markets, Talent, Risk Management, Assurance, Advisory, Tax, and Transaction Advisory Services.

Global Practice Group

This group brings together the members of the GE, GE committees, Regional leaders and sector leaders. The Global Practice Group seeks to promote a common understanding of EY’s strategic objectives and helps drive consistency of execution across the organization.

EYG member firms

Under the regulations of EYG, member firms commit themselves to pursue EY’s objectives, such as the provision of high-quality service worldwide. To that end, the member firms undertake the implementation of global strategies and plans, and work to maintain the prescribed scope of service capability. They are required to comply with common standards, methodologies and policies, including those regarding audit methodology, quality and risk management, independence, knowledge sharing, human resources, and technology.

Above all, EYG member firms commit to conducting their professional practices in accordance with applicable professional and ethical standards, and all applicable requirements of law. This commitment to integrity and doing the right thing is underpinned by the EY Global Code of Conduct and EY values (see page 12).

Besides adopting the regulations of EYG, member firms enter into several other agreements covering aspects of their membership in the EY organization, such as the right and obligation to use the EY name, and the sharing of knowledge.

Member firms are subject to reviews that evaluate their adherence to EYG requirements and policies governing issues such as independence, quality and risk management, audit methodology, and human resources. Member firms unable to meet the quality commitments and other EYG membership requirements may be subject to separation from the EY organization.


Commitment to qualityInfrastructure supportingqualityQuality in our service linesVision 2020+, which sets out EY’s purpose, ambition andstrategy, calls for EYG member firms to provide exceptionalclient service worldwide. This is supported by an unwaveringcommitment to quality and service that is professionally andglobally consistent, and means service that is based onobjectivity, professional skepticism, and adherence to EYand professional standards.

EYG member firms and their service lines are accountablefor delivering quality engagements. EY service lines managethe overall process for quality reviews of completedengagements and input for the quality of in-processengagements, which helps achieve compliance withprofessional standards and EY policies.

Vision 2020+ has reinforced the ownership of qualityby the service lines, including audit. It has alsoresulted in increased clarity around the role of riskmanagement in policies and practices that support andimprove audit quality.

The Global Vice Chair of Assurance coordinates memberfirms’ compliance with EY policies and procedures forassurance services.

Professional PracticeThe Global Vice Chair of Professional Practice, referred to asthe Global Professional Practice Director (PPD), is overseenby the Global Vice Chair of Assurance and works to establishglobal audit quality control policies and procedures. Each ofthe Area PPDs is overseen by the Global PPD and the relatedArea Assurance Leader. This helps provide greaterassurance as to the objectivity of audit quality andconsultation processes.

The Global PPD also leads and oversees the GlobalProfessional Practice group. This is a global network oftechnical subject matter specialists in accounting andauditing standards, who consult on accounting, auditing andfinancial reporting matters, and perform various practicemonitoring and risk management activities.

The Global PPD oversees development of the EY GlobalAudit Methodology (EY GAM) and related technologies sothat they are consistent with relevant professionalstandards and regulatory requirements. The GlobalProfessional Practice group also oversees the developmentof the guidance, training and monitoring programs andprocesses used by member firm professionals to executeaudits consistently and effectively. The Global, Area andRegion PPDs, together with other professionals who workwith them in each member firm, are knowledgeable aboutEY people, clients and processes, and they are readilyaccessible for consultation with audit engagement teams.

Additional resources often augment the Global ProfessionalPractice group, including networks of professionalsfocused on:

• Internal—control reporting and related aspects of the EYaudit methodology

• Accounting, auditing and risk issues for specificindustries and sectors

• Event-specific issues involving areas of civil and politicalunrest; or sovereign debt and related accounting,auditing, reporting and disclosure implications

• General engagement issues and how to work effectivelywith audit committees

Risk managementResponsibility for high-quality service and ownership of therisks associated with quality is placed with the member firmsand their service lines. Among other things, the Global RiskManagement Leader helps oversee the management ofthese risks by the member firms, as well as other risksacross the organization as part of the broader EnterpriseRisk Management framework.

Member firm partners are appointed to lead riskmanagement initiatives in both the service lines andmember firms, supported by other staff and professionals.The Global Risk Management Leader is responsible forestablishing globally consistent risk management executionpriorities and enterprise—wide risk management.These priorities cascade to member firms, and theirexecution is monitored through an Enterprise RiskManagement program.

Global confidentiality policyProtecting confidential information is ingrained in theeveryday activities of EYG member firms. Respect for


intellectual capital and all other sensitive and restrictedinformation is required by the EY Global Code of Conduct,which provides a clear set of principles to guide thebehaviors expected of all EY people. The GlobalConfidentiality Policy further details this approach toprotecting information and reflects the ever—increasing useof restricted data. This policy provides added clarity for EYpeople and forms the fundamental element of broaderguidance that includes key policies on conflicts of interest,personal data privacy and records retention. Other guidanceincludes:

• Social media guidance• Information—handling requirements• Knowledge—sharing protocols

Cybersecurity

Managing the risk of major and complex cybersecurityattacks is a part of doing business for all organizations.While no systems are immune from the threat of cyber—attacks, EY Greece is vigilant in the steps taken to secure theenvironment of EYG member firms and to protect theirclients’ data. The EY approach to cybersecurity is proactiveand includes the implementation of technologies andprocesses necessary to manage and minimize cybersecurityrisks globally. EY information security and data privacyprograms, consistent with industry practices and applicablelegal requirements, are designed to protect againstunauthorized disclosure of data. There is a dedicated teamof internal and external cybersecurity specialists whoactively monitor and defend EY systems.

Beyond technical and process controls, all EY people arerequired to affirm in writing their understanding of theprinciples contained in the EY Global Code of Conduct andtheir commitment to abide by them and to participate in anannual security awareness learning activity. There arevarious policies outlining the due care that must be takenwith technology and data, including but not limited to theGlobal Information Security Policy, and a global policyaround the Acceptable Use of Technology. EY cybersecuritypolicies and processes recognize the importance of timelycommunication. EY people receive regular and periodiccommunications reminding them of their responsibilitiesaround these policies and general security awarenesspractice.

Components of the audit quality control programIn the following sections, we describe the principalcomponents of the audit quality control program, which EYHellas follows:

• Instilled professional values• Internal quality control system• Client acceptance and continuance• Performance of audits• Review and consultation• Audit partner rotation• Audit quality reviews• External quality—assurance reviews• Compliance with legal requirements

Instilled professional valuesSustainable Audit QualityQuality is the foundation for exceptional client service. It iswhat we pride ourselves on. It is integral to our work andcentral to our responsibility to provide confidence to thecapital markets. Delivering quality is at the heart of all wedo and supports our purpose of building a better workingworld for our people, our clients and our communities. Thisis reflected in the Sustainable Audit Quality (SAQ) program,which is the highest priority for our Assurance practices.

Each member firm that makes up our global structure iscommitted to providing high-quality audits. In 2015, welaunched the SAQ initiative throughout our Assurancepractices. SAQ establishes a governance structure and isfocused on continuously improving our audit process.

We use the word “sustainable” in SAQ to demonstrate thatthis is not a one-off, short-term initiative, but an ongoingprocess of improvement. EY has had a common auditmethodology for some time; now we have a commonlanguage and processes regarding audit quality.

There are six components to SAQ: tone at the top,strengthening people capabilities, simplification, audittechnology and digital, enablement and quality support, andaccountability. SAQ is implemented by each member firm,and is coordinated and overseen globally.

Audit quality and the key elements of SAQ are somethingevery senior manager, manager and team member mustunderstand and be committed to implementing locally. SAQis essential to all our goals and ambitions, and each of theRegional and Area leaders is held accountable for thosegoals.

We have made significant progress through SAQ. EY’sinternal and external inspection findings globally areshowing improvement, and we are producing greaterconsistency in execution. We have deployed world—classtools that enhance the quality and value of our audits. Ourability to deliver consistency is based in part on the use ofEY Canvas, our online audit platform. It better supportsaudit execution, streamlines communications and enablesus to provide a seamless audit.

We recently launched the EY Canvas Client Portal, whichadds to the leading—edge tools already offered to ourauditors. In addition, we have deployed the 2018 AuditMilestones Program globally, which establishes the use ofMilestones on selected PIE audits as one important step toimproving results and sustaining quality acrossengagements.

There is also a network of Quality Enablement Leaders(QELs) across the practice and an overall Global AuditQuality Committee.

They help us in executing and reviewing root-cause analysisand understanding the impact our initiatives are having indriving quality outcomes, better behaviors and a continuousimprovement mindset. This infrastructure demonstratesthat audit quality is the single most important factor in our


decision—making and the key measure on which ourprofessional reputation stands.

Tone at the topEY Hellas’ leadership is responsible for setting the right toneat the top and demonstrating EY’s commitment to buildinga better working world through behavior and actions. Whilethe tone at the top is vital, our people also understand thatquality and professional responsibility start with them. Ourshared values, which inspire our people and guide them todo the right thing, and our commitment to quality areembedded in who we are and in everything we do.

The EY approach to business ethics and integrity iscontained in the EY Global Code of Conduct and otherpolicies, and is embedded in the EY culture of consultation,training programs and internal communications. Seniormanagement regularly reinforces the importance ofperforming quality work, complying with professionalstandards, adhering to our policies, leading by example andthrough various communications. Also, EY’s quality reviewprograms assess professional service as a key metric inevaluating and rewarding all professionals.

The EY culture strongly supports collaboration and placesspecial emphasis on the importance of consultation indealing with complex or subjective accounting, auditing,reporting, regulatory and independence matters. We believeit is important to determine that engagement teams andclients correctly follow consultation advice, and weemphasize this when necessary.

The consistent stance of EY Hellas has been that noclient is more important than our professionalreputation — the reputation of EY Hellas and thereputation of each of our professionals.

Code of ConductWe promote a culture of integrity among our professionals.The EY Global Code of Conduct provides a clear set ofprinciples that guide our actions and our business conduct,and are to be followed by all EY personnel. The EY GlobalCode of Conduct is divided into five categories:

• Working with one another• Working with clients and others• Acting with professional integrity• Maintaining our objectivity and independence• Respecting intellectual capital

Through our procedures to monitor compliance withthe EY Global Code of Conduct, and through frequentcommunications, we strive to create an environment thatencourages all personnel to act responsibly, includingreporting misconduct without fear of retaliation.

The EY Ethics Hotline provides our people, clients andothers outside of the organization with a means toconfidentially report activity that may involve unethical orimproper behavior and that may be in violation ofprofessional standards or otherwise inconsistent with the EYGlobal Code of Conduct. The hotline is operated by an

external organization that provides confidential and, ifdesired, anonymous hotline reporting services worldwide.

When a report comes into the EY Ethics Hotline, either byphone or internet, it receives prompt attention. Dependingon the content of the report, appropriate individuals fromRisk Management, Talent, Legal or other functions areinvolved to address the report. The same procedures arefollowed for matters that are reported outside of the EYEthics Hotline.

Our values: who we are

People who demonstrate integrity, respect and teaming

People with energy, enthusiasm and the courage to lead

People who build relationships based on doing the rightthing

Internal quality control systemStructureEY Hellas’ reputation for providing high-quality professionalaudit services independently, objectively and ethically isfundamental to our success as independent auditors. Wecontinue to invest in initiatives to promote enhancedobjectivity, independence and professional skepticism.These are fundamental attributes of a high-quality audit.

At EY Hellas, our role as auditors is to provide assurance onthe fair presentation of the financial statements of thecompanies we audit. We bring together qualified teams toprovide our services, drawing on our broad experienceacross industry sectors and services. We continually striveto improve our quality and risk management processes sothat the quality of our service is at a consistently high level.

We recognize that in today’s environment — characterized bycontinuing globalization and the rapid movement of capitaland the impact of technology changes — the quality of ouraudit services has never been more important. As part of EYVision 2020+, we continue to invest heavily in developingand maintaining our audit methodology, tools and otherresources needed to support quality service.

While the market and stakeholders continue to demandhigh-quality audits, they also demand increasingly efficientand effective delivery of audit services. In addition to theinvestments mentioned, EY continues to seek ways toimprove the effectiveness and efficiency of its auditmethodology and processes, while improving audit quality.

We work to understand where our audit quality may not beup to our own expectations and those of stakeholders,including external audit firm regulators. We seek to learnfrom external and internal inspection activities and toidentify root causes of adverse quality occurrences toenable us continually to improve audit quality, and webelieve that taking effective and appropriate actions toimprove quality is important.


Effectiveness of the quality control systemEY has designed and implemented a comprehensive set ofglobal audit quality control policies and practices. Thesepolicies and practices meet the requirements of theInternational Standards on Quality Control issued by theInternational Auditing and Assurance Standards Board(IAASB). EY Hellas has adopted these global policies andprocedures, and has supplemented them as necessary tocomply with local laws and professional guidelines, and toaddress specific business needs.

We also execute the EY Audit Quality Review (AQR) programto evaluate whether our system of audit quality control hasoperated effectively so as to provide reasonable assurancethat EY Hellas and our people comply with applicableprofessional standards, internal policies and regulatoryrequirements.

The results of the AQR program and external inspections areevaluated and communicated within EY Hellas to provide thebasis for continual improvement in audit quality, consistentwith the highest standards in the profession.

The GE is responsible for implementing qualityimprovement. As such, it reviews the results of our internalAQR program and external audit firm regulatory reviews, aswell as any key actions designed to address areas forimprovement.

The recent results of such monitoring, together with therecent feedback from independent external audit firmregulators, provide EY Hellas with a basis to conclude thatour internal control systems are designed appropriately andare operating effectively. In addition, EY Hellasmanagement system is ISO 9001:2015 certified by BureauVeritas.

Client acceptance andcontinuanceEY policyThe EY Global Client Acceptance and Continuance Policysets out principles for member firms to determine whetherto accept a new client or a new engagement, or to continuewith an existing client or engagement. These principles arefundamental to maintaining quality, managing risk,protecting our people and meeting regulatory requirements.The objectives of the policy are to:

• Establish a rigorous process for evaluating risk andmaking decisions to accept or continue clients orengagements

• Meet applicable independence requirements• Identify and deal appropriately with any conflicts of

interest• Identify and decline clients or engagements that pose

excessive risk• Require consultation with designated professionals to

identify additional risk management procedures forspecific high-risk factors

• Comply with legal, regulatory and professionalrequirements

In addition, the EY Global Conflicts of Interest Policy definesglobal standards for addressing categories of potentialconflicts of interest and a process for identifying them. Italso includes provisions for managing potential conflicts ofinterest as quickly and efficiently as possible through theuse of appropriate safeguards. Such safeguards range fromobtaining a client’s consent for EYG member firms to act fortwo or more clients to declining an engagement to avoid anidentified conflict.

The EY Global Conflicts of Interest Policy and associatedguidance were updated in early 2015. The updates take intoaccount the increasing complexity of engagements andclient relationships, and the need for speed and accuracy inresponding to clients. They also align with the latestInternational Ethics Standards Board for Accountants(IESBA) standards.

Putting policy into practiceWe use the EY Process for Acceptance of Clients andEngagements (PACE), an intranet—based system, forefficiently coordinating client and engagement acceptanceand continuance activities in line with global, service lineand member firm policies. PACE takes users through theacceptance and continuance requirements, and identifiesthe policies and references to professional standardsneeded to assess both business opportunities andassociated risks.

As part of this process, we carefully consider the riskcharacteristics of a prospective client or engagement andthe results of several due diligence procedures. Before wetake on a new engagement or client, we determine whetherwe can commit sufficient resources to deliver qualityservice, especially in highly technical areas, and if theservices the client wants are appropriate for us to provide.The approval process is rigorous, and no new auditengagement may be accepted without the approval of ourPPD.

In the EY annual client and engagement continuanceprocess, we review our service and ability to continue toprovide quality service, and confirm that clients share EYHellas’ commitment to quality and transparency in financialreporting. The partner in charge of each audit, together withour Assurance leadership, annually reviews our relationshipwith the audit client to determine whether continuance isappropriate.

As a result of this review, certain audit engagements areidentified as requiring additional oversight proceduresduring the audit (close monitoring), and some audit clientsare discontinued. As with the client acceptance process, ourRegional PPD is involved in the client continuance processand must agree with the continuance decisions.

Decisions about acceptance or continuance of clients andengagements consider the engagement team’s assessmentof whether the company’s management may pressure us toaccept inappropriate accounting, auditing and reportingconclusions to undermine quality. Considerations andconclusions on the integrity of management are essential toacceptance and continuance decisions.


Performance of auditsAs part of EY Vision 2020+, EY has invested significantly inimproving audit methodologies and tools, with the goal ofperforming the highest-quality audits in the profession. Thisinvestment reflects EY’s commitment to building trust andconfidence in the capital markets and in economies theworld over.

Audit methodologyEY GAM provides a global framework for delivering high-quality audit services through the consistent application ofthought processes, judgments and procedures in all auditengagements, regardless of size. EY GAM also requirescompliance with relevant ethical requirements, includingindependence from the entity we audit. Making riskassessments, reconsidering and modifying them asappropriate, and using these assessments to determine thenature, timing and extent of audit procedures arefundamental to EY GAM. The methodology also emphasizesapplying appropriate professional skepticism in theexecution of audit procedures. EY GAM is based onInternational Standards on Auditing (ISAs) and issupplemented in Greece to comply with the local Greekauditing standards and regulatory or statutoryrequirements.

Using an online tool, EY Atlas, an EY auditor is presentedwith a version of EY GAM organized by topic and designedto focus the audit strategy on the financial statement risks,and the design and execution of the appropriate auditresponse to those risks. EY GAM consists of two keycomponents: requirements and guidance, and supportingforms and examples. The requirements and guidance reflectboth auditing standards and EY policies. The forms andexamples include leading practice illustrations, and assist inperforming and documenting audit procedures.

EY GAM can be “profiled” or tailored to present the relevantrequirements and guidance, depending on the nature of theentity being audited. For example, there are profiles forlisted entities and for those considered non-complexentities. Enhancements to the audit methodology are maderegularly to address new standards, emerging auditingissues and matters, implementation experiences, andexternal and internal inspection results. In 2017, EY GAMwas updated to address the requirements of new section225 of the International Ethics Standards Board forAccountants Code of Ethics (IESBA Code), Responding toNon-Compliance with Laws and Regulations and theresulting conforming changes to the ISAs. In addition,updated guidance was issued on performing joint audits andaudits when the entity uses a service organization, alongwith new policies relating to maintaining the auditdocumentation in electronic form. EY GAM was alsoenhanced by adding guidance to address common questionsfrom audit teams and issues arising from inspections.

In addition, we monitor current and emergingdevelopments, and issue timely audit planning and otherreminders. These reminders emphasize areas noted duringinspections as well as other key topics of interest to our local

audit regulator(s) and the International Forum ofIndependent Audit Regulators (IFIAR).

TechnologyOur audit engagement teams use technology to assist inexecuting and documenting the work performed inaccordance with EY GAM.

EY Canvas, our global audit platform, lies at the heart of theaudit and enables us to provide a high-quality audit. EYCanvas is built using HTML5, state-of-the-art technology forweb applications. This allows us to provide data security andto evolve our software to respond to changes in theaccounting profession and regulatory environment. Thepredecessor audit support tool, GAMx, was decommissionedin 2018.

Through the use of profile questions, audit engagements inEY Canvas are automatically configured with informationrelevant to an entity’s listing requirements and industry.This helps to keep our audit plans customized and up-to-date, and provides direct linkage to our audit guidance,professional standards and documentation templates. EYCanvas is built with a user interface that allows the team tovisualize risks and their relationship to the planned responseand work performed in key areas. It also enables a linkagefor our group audit teams to communicate inter-office risksand instructions so that the primary audit team can directexecution and monitor performance of the group audit.

EY Canvas includes a Client Portal to assist teams incommunicating with clients and streamlining their clientrequests. Mobile applications are integrated with EY Canvasto help our people in their audit work; for example, inmonitoring the status of the audit, capturing audit evidencesecurely and performing inventory observations.

Audit engagement teams use other software applications,forms and templates during various phases of an audit toassist in executing procedures, making and documentingaudit conclusions, and performing analysis.

At EY, we are making data analysis integral to our audits.Our use of data and analysis is not about additiveprocedures or visualizations. It is about taking largepopulations of company data, and applying our globallyconsistent technology (EY Helix) and methodology (EYGAM) to audit that data.

EY Helix is a library of data analyzers for use in audits. Thesedata analyzers are transforming the audit through theanalysis of larger populations of audit-relevant data,identifying unseen patterns and trends in that data, andhelping to direct our audit efforts. The use of data analyticsalso allows us to obtain better perspectives, richer insightsand a deeper understanding of transactions and areas ofrisk.

EY is deploying data analyzers to analyze the businessoperating cycles of the companies that we audit, supportedby analytics-based audit programs to aid the application ofthese data analyzers.

Using the EY Helix library of data analyzers, ourengagement teams can enhance their audit risk


assessment, enabling the audit of higher-risk transactions,and assisting our people in asking better questions aboutaudit findings and evaluating the outcomes.

EY Atlas is a global technology platform that enables ourauditors to access the latest accounting and auditingcontent, including external standards, EY interpretationsand thought leadership.

Formation of audit engagement teamsEY Hellas’ policies require an annual review of partnerassignments by our Assurance leadership and Regional PPDto make sure that the professionals leading listed-companyaudits possess the appropriate competencies (i.e., theknowledge, skills and abilities) to fulfill their engagementresponsibilities, and are in compliance with applicableauditor rotation regulations.

The assignment of professionals to an audit engagement isalso made under the direction of our Assurance leadership.Factors considered when assigning people to audit teamsinclude engagement size and complexity, specializedindustry knowledge and experience, timing of work,continuity, and opportunities for on-the-job training. Formore complex engagements, consideration is given towhether specialized or additional expertise is needed tosupplement or enhance the audit engagement team.

In many situations, internal specialists are assigned as partof the audit engagement team to assist in performing auditprocedures and obtaining appropriate audit evidence. Theseprofessionals are used in situations requiring special skillsor knowledge, such as information systems, asset valuationand actuarial analysis.

Review and consultationReviews of audit workEY policies describe the requirements for timely and directsenior professional participation, as well as the level ofreview required for the work performed. Supervisorymembers of an audit engagement team perform a detailedreview of the audit documentation for accuracy andcompleteness. Senior audit executives and engagementpartners perform a second-level review to determineadequacy of the audit work as a whole, and the relatedaccounting and financial statement presentation. A taxprofessional reviews the significant tax and other relevantworking papers. For listed and certain other companies, anengagement quality reviewer (described below) reviewsimportant areas of accounting, financial reporting and auditexecution, as well as the financial statements of thecompany we audit and our auditor’s report.

The nature, timing and extent of the reviews of audit workdepend on many factors, including:

• The risk, materiality, subjectivity and complexity of thesubject matter

• The ability and experience of the audit team memberspreparing the audit documentation

• The level of the reviewer’s direct participation in theaudit work

• The extent of consultation employed

Our policies also describe the roles and responsibilities ofeach audit engagement team member for managing,directing and supervising the audit, as well as therequirements for documenting their work and conclusions.

Consultation requirementsEY consultation policies are built upon a culture ofcollaboration, whereby audit professionals are encouragedto share perspectives on complex accounting, auditing andreporting issues. Consultation requirements and relatedpolicies are designed to involve the right resources so thataudit teams reach appropriate conclusions.

Consultation is built into the decision-making process;it is not just a process to provide advice.

For complex and sensitive matters, we have a formal processrequiring consultation outside of the audit engagementteam with other personnel who have more experience orspecialized knowledge, primarily Professional Practice andIndependence personnel. In the interests of objectivity andprofessional skepticism, our policies require members ofProfessional Practice, Independence and certain others towithdraw from a consultation if they currently serve, or haverecently served, the client to which the consultation relates.In this circumstance, other appropriate individuals would beassigned.

EY policies also require that we document all consultations,including written concurrence from the person or personsconsulted, in order to demonstrate their understanding ofthe matter and its resolution.

Engagement quality reviewsEngagement quality reviews are performed by auditpartners in compliance with professional standards foraudits of all listed companies and those considered closemonitoring. Engagement quality reviewers are experiencedprofessionals with significant subject matter knowledge.They are independent of the engagement team and able toprovide objective evaluation of significant accounting,auditing and reporting matters. In no circumstances may theresponsibility of the engagement quality reviewer bedelegated to another individual.

The engagement quality review spans the entireengagement cycle, including planning, risk assessment,audit strategy and execution. Policies and procedures forthe performance and documentation of engagement qualityreviews provide specific guidelines on the nature, timing andextent of the procedures to be performed, and the requireddocumentation evidencing their completion. Our RegionalPPD approves all engagement quality review assignments.

Audit engagement team resolution process fordifferences of professional opinionEY has a collaborative culture that encourages and expectspeople to speak up, without fear of reprisal, if a difference


of professional opinion arises or if they are uncomfortableabout a matter relating to a client engagement. Policies andprocedures are designed to empower members of an auditengagement team to raise any disagreements relating tosignificant accounting, auditing or reporting matters.

These policies are made clear to people as they join EY, andwe continue to promote a culture that reinforces a person’sresponsibility and authority to make their own views heard,and seek out the views of others.

Differences of professional opinion that arise during an auditare generally resolved at the audit engagement team level.However, if any person involved in the discussion of an issueis not satisfied with the decision, they refer it to the nextlevel of authority until agreement is reached or a finaldecision is made.

Furthermore, if the engagement quality reviewer makesrecommendations that the engagement partner does notaccept or the matter is not resolved to the reviewer’ssatisfaction, the auditor’s report is not issued until thematter is resolved. EY policies require documentation ofdisagreements and their resolution.

Audit partner rotationEY supports mandatory audit partner rotation to helpreinforce auditor independence. EY Hellas complies with theaudit partner rotation requirements of the code of theIESBA, Regulation (EU) 537/2014 of the EuropeanParliament and of the Counsel of 16 April 2014 (EU537/2014), the Greek legislation rotation requirements, aswell as the U.S. Securities and Exchange Commission (SEC),where required. EY Hellas supports audit partner rotationbecause it provides a fresh perspective and promotesindependence from company management, while retainingexpertise and knowledge of the business. Audit partnerrotation, combined with independence requirements,enhanced systems of internal quality controls andindependent audit oversight, helps strengthenindependence and objectivity, and are important safeguardsof audit quality.

For PIEs where rotation of the audit partner is not mandatedby local independence regulation or is less restrictive thanthe IESBA or EU 537/2014 requirements, the EY GlobalIndependence Policy requires the lead engagement partnerand the engagement quality reviewer to be rotated afterseven years. For a new PIE (including a newly listedcompany) client, the lead engagement partner and theengagement quality reviewer may remain in place for anadditional two years before rotating off the team, if theyhave served the client for six or more years prior to thelisting. Following rotation, the partner may not resume thelead or engagement quality review role until at least twoyears have elapsed.

We employ tools to track partner rotation that enableeffective monitoring of compliance with requirements.We have also implemented a process for partner rotationplanning and decision-making that involves consultation

with, and approvals by, our Professional Practice andIndependence professionals.

Audit quality reviewsThe EY Global AQR program is the cornerstone of the EYprocess to monitor audit quality. EY Hellas executes theGlobal AQR program, reports results and developsresponsive actions plans. The primary goal of the programis to determine whether systems of quality controls,including those of EY Hellas, are appropriately designed andfollowed in the execution of audit engagements to providereasonable assurance of compliance with policies andprocedures, professional standards, and regulatoryrequirements. The Global AQR program complies withguidelines in the International Standard on Quality ControlNo. 1 (ISQC No. 1), as amended, and is supplemented wherenecessary to comply with Greek professional standards andregulatory requirements. It also aids EY Hellas’ continualefforts to identify areas where we can improve ourperformance or enhance our policies and procedures.

Executed annually, the program is coordinated andmonitored by representatives of the Global PPD network,with oversight by Global Assurance leadership.

The engagements reviewed each year are selected on a risk-based approach, emphasizing audit engagements that arelarge, complex or of significant public interest. The GlobalAQR program includes detailed risk-focused file reviewscovering a large sample of listed and non-listed auditengagements to measure compliance with internal policiesand procedures, EY GAM requirements, and relevant localprofessional standards and regulatory requirements. It alsoincludes reviews of a sample of non-audit engagements.These measure compliance with the relevant professionalstandards and internal policies and procedures that shouldbe applied in executing non-audit services. In addition,practice-level reviews are performed to assess compliancewith quality control policies and procedures in the functionalareas set out in ISQC No. 1. The Global AQR programcomplements external practice monitoring and inspectionactivities, such as inspection programs executed by auditregulators and external peer reviews.

AQR reviewers and team leaders are selected for their skillsand professional competence in accounting and auditing, aswell as their industry specialization; they often work in theGlobal AQR program for a number of years and are highlyskilled in the execution of the program. Team leaders andreviewers are assigned to inspections outside of their homelocation and are independent of the audit teams reviewed.

The results of the Global AQR program, external practicemonitoring and inspection activities are evaluated andcommunicated to improve quality. Any quality improvementplans describe the follow-up actions to be taken, the peopleresponsible, the timetable and deadlines, and sign-off oncompleted actions. Measures to resolve audit qualitymatters noted from the Global AQR program, regulatoryinspections and peer reviews are addressed by Assuranceleadership and our PPD. The actions are monitored by ourPPD and Assurance leadership. These programs provide


important practice monitoring feedback for our continuingquality improvement efforts.

External quality assurancereviewEY Hellas’ audit practices and our registered statutoryauditors are subject to inspection by the HellenicAccounting and Auditing Standards Board (ELTE), to beperformed at least every 3 years. As part of its inspections,ELTE evaluates quality control systems and reviews selectedengagements. Furthermore, EY Hellas is registered with thePublic Company Accounting Oversight Board (PCAOB) in theUnited States of America and, therefore, subject to itsinspections as well.

The last quality assurance inspection took place in October2017, jointly by ELTE and PCAOB. PCAOB’s final report onthe inspection was issued in April 2018 with no findings.Furthermore, within April 2018, we provided responses toELTE’s draft inspection reports, within July 2018 had ahearing with ELTE’s Quality Inspection Board (SPE) and weare expecting the issuance of ELTE’s final inspectionreports.

We respect and benefit from the inspection process. Wethoroughly evaluate points raised during the inspection inorder to identify areas where we can improve audit quality.Together with the AQR process, external inspections aid usin making our audits and related control processes of thehighest quality in the interests of our clients’ investors andother stakeholders.

Information on the above-mentioned regulators can befound at http://www.elte.org and https://www.pcaobus.org.

Compliance with legalrequirementsThe EY Global Code of Conduct provides a clear set ofstandards that guide our actions and business conduct.EY Greece complies with applicable laws and regulations,and EY’s values underpin our commitment to doing the rightthing. This important commitment is supported by a numberof policies and procedures, explained in the paragraphsbelow.

Anti-briberyThe EY Global Anti-bribery Policy provides EY people withdirection around certain unethical and illegal activities. Itemphasizes the obligation to comply with anti-bribery lawsand provides greater definition of what constitutes bribery.It also identifies reporting responsibilities when bribery isdiscovered. In recognition of the growing global impact ofbribery and corruption, efforts have been increased toembed anti-bribery measures across EY.

Insider tradingThe EY Global Insider Trading Policy reaffirms the obligationof our people not to trade in securities with insiderinformation, provides detail on what constitutes insider

information and identifies with whom our people shouldconsult if they have questions regarding theirresponsibilities.

Trade sanctionsIt is important that we are aware of the ever—changingsituation with respect to international trade sanctions. EYmonitors sanctions issued in multiple geographies andprovides guidance to EY people on impacted activities.

Data privacyThe EY Global Personal Data Privacy Policy sets out theprinciples to be applied to the use and protection of personaldata, including that relating to current, past and prospectivepersonnel, clients, suppliers, and business associates. Thispolicy is consistent with applicable laws and regulationsconcerning data protection and privacy for maintaining andprocessing personal data. Furthermore, we have a policy toaddress our specific Greek data privacy requirements andbusiness needs.

Document retentionEY Hellas’ record retention policy applies to all engagementsand personnel. This policy addresses documentpreservation whenever any person becomes aware of anyactual or reasonably anticipated claim, litigation,investigation, subpoena or other government proceedinginvolving us or one of our clients that may relate to ourwork. It also addresses Greek legal requirements applicableto the creation and maintenance of working papers relevantto the work performed.


Independence practicesEY Global Independence policies require EY Greece and ourpeople to comply with the independence standardsapplicable to specific engagements, including, for example,the Code of Ethics of the IESBA, the EU Regulation537/2014 and Law 4449/2017.

We consider and evaluate independence from severalperspectives, including our financial relationships and thoseof our people; employment relationships; businessrelationships; the permissibility of non-audit services weprovide to audit clients; applicable firm and partner rotationrequirements; fee arrangements; audit committee pre-approval, where applicable; and partner remuneration andcompensation.

Failure to comply with applicable professionalindependence requirements will factor into decisionsrelating to a person’s promotion and compensation,and may lead to other disciplinary measures, includingseparation from EY Greece.

EY Greece has implemented EY’s global applications, toolsand processes to support us, our professionals and otheremployees in complying with independence policies.

EY Global Independence PolicyThe EY Global Independence Policy contains theindependence requirements for member firms,professionals and other personnel. It is a robust policypredicated on the IESBA Code of Ethics and supplementedby more stringent requirements where prescribed by a givenregulator. The policy also contains guidance to help peopleapply the independence rules. The EY Global IndependencePolicy is readily accessible and easily searchable on the EYintranet.

Global Independence System (GIS)The GIS is an intranet—based tool that helps EY professionalsidentify the listed entities from which independence isrequired and the independence restrictions that apply. Mostoften, these are listed audit clients and their affiliates, butthey can be other types of attest or assurance clients too.The tool includes family—tree data relating to affiliates oflisted audit clients and is updated by client—servingengagement teams. The entity data includes notations that

indicate the independence rules that apply to each entity,helping our people determine the type of services that canbe provided or other interests or relationships that can beentered into.

Global Monitoring System (GMS)The GMS is another important global tool that assists inidentifying proscribed securities and other impermissiblefinancial interests. Professionals ranked as manager andabove are required to enter details about all securities theyhold, or those held by their immediate family, into the GMS.When a proscribed security is entered or if a security theyhold becomes proscribed, professionals receive a notice,and are required to dispose of the security. Identifiedexceptions are reported through the Global IndependenceIncident Reporting System (GIIRS) for regulatory matters.

GMS also facilitates annual and quarterly confirmation ofcompliance with independence policies, as described below.

Independence complianceEY has established a number of processes and programsaimed at monitoring the compliance with independencerequirements of EY member firms and their people. Theseinclude the following activities, programs and processes.

Independence confirmations

Annually, EY Greece is included in an Area-wide process toconfirm compliance with the EY Global Independence Policyand process requirements, and to report identifiedexceptions, if any.

All EY professionals, and certain others, based on their roleor function, are required to confirm compliance withindependence policies and procedures at least once a year.All partners are required to confirm compliance quarterly.

Independence compliance reviews

EY conducts internal procedures to assess member firmcompliance with independence matters. These reviewsinclude aspects of compliance related to non-audit services,business relationships with the companies we audit andfinancial relationships of member firms.


Personal independence compliance testing

Each year, the EY Global Independence team establishes aprogram for testing compliance with personal independenceconfirmation requirements and with reporting ofinformation into GMS. For the 2017 testing cycle, EY Greecetested more than 21 partners and other personnel.

Non-audit services

We monitor compliance with professional standardsgoverning the provision of non-audit services to audit clientsthrough a variety of mechanisms. These include the use oftools, such as PACE (see page 13) and Service OfferingReference Tool (see below), and training and requiredprocedures completed during the performance of audits andinternal inspection processes. We also have a process inplace for the review and approval of certain non-auditservices in advance of accepting the engagement.

Global independence learning

EY develops and deploys a variety of independence learningprograms. All professionals and certain other personnel arerequired to participate in annual independence learning tohelp maintain our independence from the companies weaudit.

The goal is to help EY people understand theirresponsibility and to enable each of them, and theirmember firms, to be free from interests that might beregarded as incompatible with objectivity, integrity andimpartiality in serving an audit client.

The annual independence learning program coversindependence requirements focusing on recent changes topolicy, as well as recurring themes and topics of importance.Timely completion of annual independence learning isrequired and is monitored closely.

In addition to the annual learning program, independenceawareness is promoted through a number of events andmaterials, including new-hire programs, milestone programsand core service line curricula.

Service Offering Reference Tool (SORT)

We assess and monitor our portfolio of services on anongoing basis to confirm that they are permitted by law andprofessional standards, and to make sure that we have theright methodologies, procedures and processes in place asnew service offerings are developed. We restrict servicesfrom being provided that could present undue independenceor other risks. SORT provides EY people with informationabout EY service offerings. It includes guidance aroundwhich services can be delivered to audit and non-auditclients, as well as independence and other risk managementissues.

Business Relationship Evaluation Tool (BRET)

The BRET process helps to support compliance withindependence requirements. Our people are required to useBRET in many circumstances to identify, evaluate and obtainadvance approval of a potential business relationship withan audit client.

Audit committees and oversight of independenceWe recognize the important role audit committees andsimilar corporate governance bodies undertake in theoversight of auditor independence. Empowered andindependent audit committees perform a vital role on behalfof shareholders in protecting independence and preventingconflicts of interest. We are committed to robust and regularcommunication with audit committees or those chargedwith governance. Through EY quality review programs, wemonitor and test compliance with EY standards for auditcommittee communications, as well as the pre-approval ofnon-audit services, where applicable.


Continuing education ofaudit professionalsProfessional developmentThe EY career development framework, EYU, provides ourpeople with opportunities for the right experiences, learningand coaching to help them grow and achieve their potential.

The learning component of EYU is based on an extensive andglobally consistent learning curriculum that helps all EYpeople develop the right technical and personal leadershipskills, wherever they are located around the world. The EYaudit core curriculum, The Audit Academy, combinesinteractive classroom-based simulations and “on-demand”e-learning modules with relevant reinforcement andapplication support. This high impact and award-winninglearning is supplemented by learning programs that aredeveloped in response to changes in accounting andreporting standards, independence and professionalstandards, and emerging practice issues.

Where an EYG member firm audits and reviews InternationalFinancial Reporting Standards (IFRS) financial statements,relevant team members undertake learning to become IFRS-accredited.

EY Hellas requires our audit professionals to obtain at least20 hours of continuing professional education each year andat least 120 hours over a three-year period. Of these hours,40% (8 hours each year and 48 hours over a three-yearperiod) must cover technical subjects related to accountingand auditing.

In addition to formal learning, professional developmentoccurs through coaching and experiences our professionalsreceive on-the-job. Coaching helps to transform knowledgeand experience into practices.

Experienced professionals are expected to coach anddevelop less-experienced personnel to create a continuallearning environment. We also manage the assignment ofour people to particular engagements in a systematic waythat helps provide them exposure to a range of experiencesas part of their own development.

Knowledge and internal communicationsIn addition to professional development and performancemanagement, we understand the importance of providingclient engagement teams with up-to-date information tohelp them perform their professional responsibilities. EYmakes significant investments in knowledge andcommunication networks to enable the rapid disseminationof information to help people collaborate and share bestpractices. Examples include:

• EY Atlas, which includes local and internationalaccounting and auditing standards, as well asinterpretive guidance; replacement for GlobalAccounting and Auditing Information Tool (GAAIT)since the fiscal year 2017

• Publications such as International GAAP, IFRSdevelopments and illustrative financial statements

• Global Accounting and Auditing News, a weekly updatecovering assurance and independence policies,developments from standard setters and regulators, aswell as internal commentary thereon

• Practice alerts and webcasts covering a range of globaland country-specific matters designed for continuousimprovement in member firms’ Assurance practices

Performance managementLEAD, our new, forward-looking approach to people’scareer, development and performance sees an enhancedfocus on continuous feedback resulting in betterconversations built around 90-day cycles. Feedback isaggregated and used as an input to compensation andreward programs.

LEAD is designed to support the growth and development ofour people at all stages of their career at EY. An individual’spersonal dashboard provides an easy to interpret snap-shotof their performance against the Leadership at EYdimensions, and assess performance against peers.

LEAD retains components that were also included in ourprevious Performance Management and DevelopmentProcess approach. Those were providing our people withclear work expectations and the opportunity to self-assesstheir performance. During the course of the year, everyprofessional, in conjunction with their counselor, identifiesopportunities for further development.


Revenue andremunerationFinancial informationRevenue represents combined, not consolidated, revenuesand includes revenues related to billings to other EYGmember firms. Revenue amounts disclosed in this reportinclude revenues from both audit and non-audit clients.

Revenue is presented in accordance with InternationalFinancial Reporting Standards as adopted by the EuropeanUnion and included for:

1. Revenues from the statutory audit of annual andconsolidated financial statements of PIEs, and entitiesbelonging to a group of undertakings whose parentundertaking is a PIE

2. Revenues from the statutory audit of annual andconsolidated financial statements of other entities

3. Revenues from permitted non-audit services to entitiesthat are audited by the statutory auditor or theaudit firm

4. Revenues from non-audit services to other entities

Financial information for the period ended 30 June2018 expressed in millions of Euro (€)

Service Revenue Percent

Statutory audits anddirectly related servicesfor PIEs

4.6 18%

Other audit services anddirectly related servicesfor non-PIEs

13.4 53%

Non-audit servicesprovided to audit clients 2.6 10%

Non-audit servicesprovided to other entities 4.8 19%

Total revenue related toEY Hellas

25.4 100%

Non-audit servicesprovided by other EYGreece entities

63.2

Total revenue of EYGreece

88.6

Partner remunerationQuality is at the center of the EY strategy and is a keycomponent of EY performance management systems. EYGreece’s partners and other professionals are evaluated andcompensated on the basis of criteria that include specificquality and risk management indicators, covering bothactions and results.

LEAD for partners, principals, executive directors anddirectors (PPEDDs) applies to all partners in EYG memberfirms around the world. LEAD for PPEDDs reinforces theglobal business agenda by continuing to link performance towider goals and values. The process includes goal setting,ongoing feedback, personal development planning andperformance review, and is tied to partners’ recognition andreward. Documenting partners’ goals and performance isthe cornerstone of the evaluation process. A partner’s goalsare required to reflect various global priorities, one of whichis quality.

EY prohibits evaluating and compensating lead auditengagement partners and other key audit partners on anengagement based on the sale of non-Assurance services totheir audit clients. This reinforces to our partners theirprofessional obligation to maintain our independence andobjectivity. For audits conducted in accordance with therequirements of Directive 2014/56/EU of the EuropeanParliament and of the Council of 16 April 2014, EY prohibitsevaluating and compensating any partner or professionalinvolved in, or able to influence the carrying out of, anengagement based on the sale of non-Assurance services totheir audit clients. This reinforces that professionals areobligated to maintain independence and objectivity.

Specific quality and risk performance measures have beendeveloped to account for:

• Providing technical excellence• Living the EY values as demonstrated by behaviors and

attitude


• Demonstrating knowledge of, and leadership in, qualityand risk management

• Complying with policies and procedures• Complying with laws, regulations and professional

duties• Contributing to protecting and enhancing the EY brand

The EY partner compensation philosophy calls formeaningfully differentiated rewards based on a partner’slevel of performance, as measured within the context ofLEAD. Partners are assessed by their firms annually on theirperformance in delivering quality, exceptional client serviceand people engagement alongside financial and marketmetrics.

To recognize different market values for different skills androles, and to attract and retain high-performing individuals,the following factors are also considered when we determineour partners’ total reward:

• Experience• Role and responsibility• Long-term potential

Instances of non-compliance with quality standards result inremedial actions, which may include compensationadjustment, additional training, additional supervision orreassignment. A pattern of non-compliance or particularlyserious non-compliance may result in actions that includeseparation from EY Greece.

We operate under a system that requires quality to bea significant consideration in a partner’s overall year-end rating.


Appendix 1: EY Hellas PIE audit clientsIn the fiscal year that ended on 30 June 2018, EY Hellas performed audits of the following PIEs:

PUBLIC INTEREST ENTITYSTATUTORY AUDIT

2017 2016AEGEAN AIRLINES S.A. ✔ ✔ ALUMIL ALUMINIUM INDUSTRY S.A. ✔ ✔ FCA BANK GmbH ✔ ✔ FCA INSURANCE HELLAS S.A. ✔ ✔ FORTHNET S.A. ✔ ✔ FOURLIS HOLDINGS S.A. ✔ ✔ GENERALI HELLAS S.A. ✔ ✔ HELLENIC EXCHANGES S.A. ATHENS STOCK EXCHANGE GROUP - ✔ HELLENIC FABRICS S.A. ✔ ✔ HELLENIC PETROLEUM S.A. ✔ -HOUSEMARKET S.A. ✔ ✔ NAFTEMPORIKI P. ATHANASSIADES & CO. S.A. ✔ ✔ NIREUS AQUACULTURE S.A. ✔ ✔ THESSALONIKI PORT AUTHORITY S.A. ✔ ✔


Appendix 2As of 30 June 2018, the following EYG member firms are approved to carry out statutory audits in an EU or EEA Member State

Member State Statutory auditor or audit firm

Austria Ernst & Young Wirtschaftspruefungsgesellschaft mbH

Belgium Ernst & Young Assurance Services BCVBA

Ernst & Young Bedrijfsrevisoren B.C.V.B.A

Bulgaria Ernst & Young Audit OOD

Croatia Ernst & Young d.o.o.

Cyprus Ernst & Young Cyprus LimitedErnst & YoungErnst & Young CEA (South) Services LtdErnst & Young CEA (South) Holdings Plc

Czech Republic Ernst & Young Audit, s.r.o.

Denmark Ernst & Young Godkendt Revisionspartnerselskab

EY Grønland Statsautoriseret Revisionspartnerselskab

Estonia Ernst & Young Baltic ASBaltic Network OU

Finland Ernst & Young Oy

Julkispalvelut EY Oy

France Artois

Auditex

Barbier Frinault & Associes

Conseil Audit & Synthese

Ernst & Young Atlantique

Ernst & Young Audit

Ernst & Young et Autres

Picarle et Associes

Germany Ernst & Young GmbH Wirtschaftsprüfungsgesellschaft

Ernst & Young Heilbronner Treuhand GmbH Wirtschaftsprüfungsgesellschaft


Member State Statutory auditor or audit firm

EY Revision und Treuhand GmbH Wirtschaftsprüfungsgesellschaft

Schitag Schwäbische Treuhand GmbH Wirtschaftsprüfungsgesellschaft

Gibraltar EY Limited

Greece Ernst & Young (Hellas) Certified Auditors Accountants SA

Hungary Ernst & Young Könyvvizsgáló Korlátolt Felelõsségû Társaság

Iceland Ernst & Young ehf

Ireland Ernst & Young Chartered Accountants

Italy EY S.p.A

Latvia Ernst & Young Baltic SIA

Liechtenstein Ernst & Young AG, BaselErnst & Young AG, Vaduz

Lithuania UAB Ernst & Young Baltic

Luxembourg Compagnie de Revision S.A.

Ernst & Young Luxembourg S.A.

Ernst & Young S.A.

Malta Ernst & Young Malta Limited

Netherlands Ernst & Young Accountants LLP

Norway Ernst & Young AS

Poland Ernst & Young Audyt Polska sp. z o.o.

Ernst & Young Audyt Polska Spółka z ograniczoną odpowiedzialnością Finance spółka komandytowa

Ernst & Young Audyt Polska spółka z ograniczoną odpowiedzialnością Doradztwo Podatkowe spółkakomandytowa

Ernst & Young Audyt Polska spółka z ograniczoną odpowiedzialnością sp. k.

Ernst & Young Usługi Finansowe Audyt sp. z o.o.

Portugal Ernst & Young Audit & Associados - SROC, S.A.

Romania Ernst & Young Assurance Services S.r.l.

Ernst & Young Support Services SRL

Slovakia Ernst & Young Slovakia, spol. s r.o.

Slovenia Ernst & Young d.o.o.

Spain ATD Auditores Sector Público, S.L.U

Ernst & Young, S.L.

Sweden Ernst & Young AB

United Kingdom Ernst & Young LLP

Ernst & Young Europe LLP

Total turnover of these EYG member firms resulting from statutory audits of annual and consolidated financial statements wasapproximately Euros 2.6 billion.

EY | Assurance | Tax | Transactions | Advisory

About EYEY is a global leader in assurance, tax, transaction and advisoryservices. The insights and quality services we deliver help build trustand confidence in the capital markets and in economies the worldover. We develop outstanding leaders who team to deliver on ourpromises to all of our stakeholders. In so doing, we play a critical rolein building a better working world for our people, for our clients andfor our communities.

EY refers to the global organization, and may refer to one or more, ofthe member firms of Ernst & Young Global Limited, each of which is aseparate legal entity. Ernst & Young Global Limited, a UK companylimited by guarantee, does not provide services to clients. For moreinformation about our organization, please visit ey.com.

©2018 Ernst & Young (Hellas) Certified Auditors Accountants S.A.All Rights Reserved.

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This material has been prepared for general informational purposesonly and is not intended to be relied upon as accounting, tax, or otherprofessional advice. Please refer to your advisors for specific advice.

This document contains information in summary form and istherefore intended for general guidance only. It is not intended to bea substitute for detailed research or the exercise of professionaljudgment. Neither EYGM Limited nor any other member of the globalEY organization can accept any responsibility for loss occasioned toany person acting or refraining from action as a result of any materialin this publication. On any specific matter, reference should be madeto the appropriate advisor.

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